BLUE FOLDER ITEM
Blue folder items are additional back up material to administrative reports and/or public commentsreceived after the printing and distribution of the agenda packet for receive and file.
CITY COUNCIL MEETING
January 11, 2022
Written Public Comment received after release of the meeting agenda N.1 DISCUSSION AND POSSIBLE ACTION ON THE CALIFORNIA DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT’S RESPONSE TO THE
CITY’S 6TH CYCLE (2021-2029) ADOPTED HOUSING ELEMENT SUBMITTAL
FOR STATECERTIFICATION
CONTACT: BRANDY FORBES, COMMUNITY DEVELOPMENT DIRECTOR
The Case Against High Density Residential at the AES Site 1 1. Executive Summary
Our community has been down this road three times in recent history just to result in three dead end wastes of years and millions of dollars. Heart of the City, Measure B, and the CenterCal mall all suffered the same fate. The track record from Redondo’s inception shows the folly of trying over develop the harbor area, especially with residential development.
It would be hard to select a site that would be more impactful and more opposed. The following paragraphs provide the evidence of the impacts and the track record of opposition. Let’s not ignore history. Save us the cost, time and divisiveness of going through a charade that will end up in failure in the end.
This is the wrong time to hand the new owner the entitlement of high density residential development.
The AES site has active wetlands. Embrace that and honor the history and cultural value of the site by commitment to major parkland and wetlands at the site. And do not take away the city’s only bargaining position with the new owner.
2. Site Not Available
The combination of climate change, power demand growth, and the lack of power grid resources to address evening demand make the current power plant shut down date questionable.
The City of Redondo and its residents have been fighting to shut down the current power plant since before 2000. With the rulings on power plants that use water cooling, the City believed the end was in sight with a mandated shut down date of December 2020. In the meantime, power outages caused by excessive heat events drove an emergency one year extension to the shut down. Commissioners assured Redondo that the date would not be extended again. However, just one year later the shut down date was extended to 2023. There is no assurance this will be the last extension. In fact, Flex Alert events this past year demonstrate that the 2020 multi-state heat wave events were not just a fluke. It takes years and billions of dollars to add new capacity to the grid to address the currently projected needs. It is highly likely the shut down date of the AES Redondo power plant will be extended again and again.
3. Required Zoning Change Unlikely To Be Approved
The Redondo Beach City Council is not the final authority of the zoning change that would be required to add residential development to the AES site. The zoning change will also drive a Local Coastal Program (LCP) change that would require certification by the Coastal Commission. Additionally, the Redondo City Charter requires a vote of the residents to approve the zoning and LCP changes. a. Coastal Act and Coastal Commission Approval for LCP Change The Coastal Commission must evaluate the submitted LCP change against the Coastal Act. The Coastal Act prioritizes coastal dependent public uses and access as well as environmental impacts over commercial and private uses. The proximity of the site to the harbor, the historic wetlands, and the poor road access create real hurdles to any meaningful increase in residential development, especially high density, largely market rate residential units.
The Case Against High Density Residential at the AES Site 2 Wetlands on the AES site – While processing AES’s application for a new power plant, the Coastal Commission found that the AES site still has active wetland activity over at least a 6 acre area centered north to south of the site and along the eastern portion of the property. This wetland site is the remnants of the historic 16 acre Salt Lake that was filled in to build the current power plant. It is situated in a strategic location along the Great Pacific Flyway relied upon by many species of migratory birds. Subsequent to the Coastal Commission finding of wetlands, the local Audubon Chapter has cataloged thousands of birds representing over 130 species using the site. Some of these species are year round residents and some are migratory birds wintering at the site. Nesting pairs and broods have been documented in the Audubon cataloging. There have been Snowy Plover and Western burrowing owl sightings immediately adjacent to the AES site. The Snowy Plover is endangered. And, the Western burrowing owl is a species of special concern in LA County. Any development of the site will require a minimum of 6 acres of wetlands and an appropriate buffer zone between the wetlands and any development on the site.
Coastal access impacts of high density residential development on the AES site – Redondo Beach is jobs poor for the workforce that is dominant in the city. As a result, a City-funded market analysis shows about 93% of working residents commute outside the city to work. There is no efficient and effective mass transit available in this area. The metro line routes require too much time and too many line changes to get to the job centers to the north, north east and east of the city. The nearest freeway access is over 20 minutes drive. That means the majority of the working residents of this potential housing center would have to drive through already gridlocked city arterials to get to their jobs. Adding traffic to already gridlocked local roads would deter access to the harbor area for coastal dependent uses by the public. The intersection of Herondo and PCH is already at capacity and at times over capacity. The only other road bordering the property is Harbor Drive which is a very narrow and already heavily used. Harbor Drive is the only access to the Harbor Area. Clogging it with more traffic would be a deterrent to public access for coastal dependent uses. With the vast majority of the residential development being market rate housing, the Coastal Commission would have to consider the impacts to low cost, coastal dependent access to the only harbor in the 25 miles of coastline between Marina Del Rey and the Port of Los Angeles.
Demonstrated intent - The combination of established wetlands and the limited access to the harbor area would likely result in significant limits on the amount of residential development approved by the Coastal Commission. Historically, the Coastal Commission forbid any new residential development just across the street from the power plant. And the Coastal Commission has demonstrated its commitment to protecting the wetlands on the AES site – it has twice ordered AES to stop dewatering activities by AES aimed at drying out the established wetlands.
Before the LCP change is even submitted to the Coastal Commission, the voters of Redondo must approve it. It is unlikely the voters of Redondo would support such a change. b. Voter approval of the required zoning change for the AES site Article XXVII of the Redondo Beach City Charter requires a vote of the residents of Redondo to approve significant zoning changes in the city. So before the City can submit any LCP change to the Coastal Commission, the change must first be approved by the voters of Redondo. Given the history of resident votes and actions related to residential development on the AES property, it is highly unlikely that the voters of Redondo would approve high density residential development on the site. A brief synopsis The Case Against High Density Residential at the AES Site 3 of these historical indications follow:
• 2002 – Residents submit a Referendum to rescind rezoning of the site for high density housing. • 2003 – Residents submit a Referendum to rescind an action of the City to create a Redevelopment Area for residential development of the AES site. • 2005 – Despite heavily biased ballot language (Figure 1), residents approve park uses of the AES site over a mixed use development alternative that included 350 residential units. • 2008 – Tired of repeated City attempts to increase residential units in the harbor/AES area, residents approve a City Charter change that requires voter approval of major zoning changes. • 2010 – Voters approve zoning change that makes “Parks” a “permitted use” on the AES site.
Public Utilities are a “conditional use” in that zoning. There are no residential uses allowed in the zoning.
• 2015 – Voters reject AES zoning initiative (Measure B) that included 650 residential units.
Voters rejected AES’s initiative despite AES’s expenditure of over $1M on a campaign that included dozens of mailers, billboards, social media ads, local publication ads, and TV ads. The addition of residential development was a major factor in the resident vote results. • 2017 – In a rare occurrence, a new Mayor candidate, Bill Brand, defeated a seated Mayor, Steve Aspel. Brand was a long term activist against overdevelopment while the sitting Mayor supported large development projects including AES’s Measure B. • 2017-2018 – Residents defeated a city-approved project to build a mall in the harbor through CEQA lawsuit, a ballot measure that rezoned the harbor (Measure C), and an appeal to the Coastal Commission. Residents were successful on all three fronts. Although this project did not include residential development, residents opposed the scale of the development, the traffic impacts of the development, and the access impacts of the development. Any meaningful residential development on the AES site would include all three impacts recently rejected by residents.
• 2021 – Voters reelect Mayor Brand and elected Council members who opposed overdevelopment. Candidates who supported overdevelopment were rejected by the voters including one sitting incumbent Council member. Again, defeating a sitting Council member is a rare event in Redondo. This recent vote demonstrates that after a decade, Redondo voters still oppose overdevelopment and the loss of quality of life in the city.
The Case Against High Density Residential at the AES Site 4 Figure 1: 2005 Redondo Advisory Vote Ballot Language. Heavily biased 2005 ballot language asked voters to choose between park uses of the AES site and mixed uses of the site that included 350 residential units. Redondo voters chose the park uses with no residential development despite the biased assessment of fiscal impacts on the community.
The voters have a clear, repeated, and ongoing track record of taking strong action against high density development, especially residential development, in the harbor area and specifically on the AES property – even in the face of strong proponents and expensive, developer-funded campaigns for the development. It is highly unlikely the voters of Redondo would approve any meaningful residential development on the AES site.
4. Economically Bad For the City
a. Already lost grant money
When the current property owner sensed an opportunity to make money with no investment by allowing the power plant to continue operations, he reneged on his commitment to sell the City 25 acres of parkland. This action resulted in the Natural Resources Agency pulling back its $4.8M grant to Redondo Beach. In parallel, this action stopped the moment on establishing the Enhanced Infrastructure Financial District.
b. Increases cost of park land and eliminates any bargaining position of the City
The loss of the one grant represents a temporary setback until the site becomes available. However, it is an indicator that the property owner will throw out previous agreements when there is a firm financial incentive to go another direction. The only leverage the City has to negotiate for meaningful parkland is The Case Against High Density Residential at the AES Site 5 the zoning entitlements the developer needs to do anything but park or public utility. If Redondo grants the owner the entitlement to high density housing, it raises the value of the land while eliminating any bargaining position for the City to negotiate any real amount of public parkland. Even if the owner still commits to major parkland, the price per acre will be significantly greater. This is the wrong time to gift a speculative real estate investor the highest value zoning. c. Exacerbates workforce/jobs imbalance
According to a City-funded market study, nearly 93% of the Redondo workforce commute out to the city to go to work. To fill the retail, hotel, and restaurant jobs that dominate the Redondo job market, over 90% of the positions are filled by workers from outside the city. Redondo has less than 1 job per household, where a city like El Segundo has 6 jobs for each household. The study shows why so many residents commute out of the Redondo to work:
“Some of the largest employment sectors for Redondo Beach residents, such as white-collar office jobs which are associated with higher- than-average wages, are dramatically under-represented in employment opportunities located in the City.”
So not only does Redondo have fewer jobs per household, the jobs that are here don’t match the Redondo workforce. Adding more high density housing that is predominantly market rate will only exacerbate this trend. The impact of this is that nearly half the population of Redondo leaves town each weekday to go to work. This is a huge loss of weekday customers to the restaurant and retail businesses that dominate Redondo’s commercial districts. That loss of customer-base results in underperforming business districts, which in turn impact the City’s sales tax revenues. It also has resulted in degradation of the quality of the business districts due to lack of investment. In recent workshops, retailers and restauranteurs from the harbor area called the harbor a “ghost town” during the workweek. Meanwhile, business districts near thriving job centers such as the Rosecrans corridor in El Segundo enjoy booming business during the workweek. Redondo needs more high end jobs, not more commuting residents, to buoy our business districts back up. Adding market rate, high density housing in the harbor area only exacerbates our current problems. d. Net loss of city revenues
The City is having an increasingly difficult time of balancing the City budget. The problem is the services required by residential development costs the City more than the revenues the City gets from the residential development. Otherwise, in a City that is over 65% zoned residential, our city coffers should be booming. More housing and more commuters only exacerbates the city’s current financial losses to residential development.
5. High Density Residential Exacerbates City Parkland Disparity The City of Redondo is “park poor” by state standards. The state’s minimum parkland threshold is 3 acres of parkland per 1000 residents. Even including the County beach, Redondo is less than 2.5 acres of parkland per 1000 residents. The cities surrounding Redondo all have over 5 acres of parkland per 1000 residents, well over double the parkland ratio of Redondo residents.
In 2011 the California Coastal Conservancy funded an study by the 606 Studio of Cal State Pomona to explore how the South Bay could add parkland. The study concluded:
The Case Against High Density Residential at the AES Site 6 “As the situation regarding the AES power plant is re-evaluated, it should be noted that the site has the strong potential to be converted to a large park. The long term vision of a large Waterfront Park at this location will provide valuable park space, create a cornerstone of the community, and serve as a major node in the [open space] connectivity network.”
Adding 25 acres of parkland at the AES site would allow the city to barely achieve the minimum threshold of 3 acres per 1000 residents. This would still fall far short of the City goal of 5 acres of parkland per 1000 residents. And of course, with infill development and state mandates, the number of residents will continue to grow – making the minimum and goal thresholds harder to achieve.
As the only reasonable opportunity to add useable parkland in the foreseeable future, using this site for residential development rather than for a large park would exacerbate Redondo’s parkland disparity.
This action would dramatically increase the number of residents while eliminating the only space to add meaningful parkland.
6. Highest Traffic Impact/Limits Harbor Access
Locating high density housing in the harbor area represents the highest traffic impact over other locations that are better suited for housing.
Redondo already suffers from gridlocked arterial roads during peak rush hours. This is driven by the poor transit system and the workforce/jobs imbalance. The table to the right, from a City-funded market study, shows over 30,000 residents leave the city each day. That is nearly half the population of Redondo. Over 90% of Redondo jobs are filled by workers who commute INTO Redondo from other communities. This clearly shows the workforce/jobs imbalance as well as the main driver of rush hour gridlock.
With the lack of efficient and effective transit alternatives, all this commuting results in traffic clogging Redondo arterials as shown in the graphic to the right. The market study shows that most Redondo workers commute to job centers to the north and northeast of the city and to the east of the southern end of the city.
Only Herondo Ave and Harbor Boulevard border the AES site. To go north and east commuters from the AES site would end up at the major intersection of Herondo and PCH or at the PCH/Torrance Blvd intersection. The City circulation element projects both intersections to be over capacity for morning and evening rush hours in 2030. And it is not just those intersections.
Commuter traffic would have to continue through the rest of Redondo no matter where the commuters work. So the traffic impact is along the entire length of Redondo arterials. It would be difficult to define a more impactful location from a traffic perspective.
Further exacerbating the situation, the harbor area can only be accessed from Harbor Drive. Harbor Drive is a single lane in each direction with multiple stop lights and heavy pedestrian and bicycle traffic.
Harbor Drive can only be accessed through Beryl, a residential street; Herondo, an overclogged arterial; and Hermosa Avenue. Clogging up traffic by adding the traffic associated with a high density housing development would block access to the coastal dependent recreational and commercial assets in the harbor. This is a violation of Coastal Act priorities. And as described earlier, Redondo voters vote The Case Against High Density Residential at the AES Site 7 against traffic and the Coastal Commission has previously limited residential development in the harbor area to protect harbor access.
7. Cultural and Historical Impacts
a. Pre-history: Salt Lake
The unique geological conditions at the AES site resulted in a 16 acre salt lake at the current AES site.
The salt lake results from a sequestered aquifer whose salinity is likely due to nearby salt deposits. The salt water is not fed by the nearby ocean waters as it is well above sea level and too high for winter storm waves and high tides. Also unique to the site, freshwater springs surfaced near the salt water lake.
b. Pre-European: Chowinga/Tongva Village and Industrial Site The Chowinga/Tongva established a village at the Salt Lake that was likely seasonal. The site was named Onoova-Ngoako, which means “Place of Salt”. The Chowinga would collect salt at the site for their use and for trade. During construction of the power plant
artifacts were discovered on the site from this occupation period.
c. Mid 1800’s to early 1900’s: Early salt
source for City of Los Angeles/Water
supply for Redondo
As the local region grew in population, a salt factory was established on the east side of the Salt Lake. Through several owners, this factory was the major source of salt for the growing City of Los Angeles. The primary road between
Redondo and Los Angeles was called the Old Salt Road. As salt from other sources became more economical, the salt factory was abandoned. The fresh water springs on the site were used to provide water to the City of Redondo in its early stages, but as the city grew, this source of water went dry.
d. 1907: First power plant
The areas first power plant, an Edison plant was
located on the north west corner of the Salt Lake.
By 1930, the plant was abandoned as other sources
of electricity were more economical.
The Case Against High Density Residential at the AES Site 8 e. 1941: Designation of Salt Lake as Historic Site
The State designated the Salt Lake as a historic site 373. f. 1944: Targeted for park site
In the 1940’s the community determined that the abandoned Edison plant should be converted to a community center and the Salt Lake and harbor area should be a large public park focused on the Salt Lake. 1944 Plan to convert the Salt Lake area to a regional park g. 1948: Construction of first units of current power plant The end of WWII resulted in a population surge in Redondo Beach and the surrounding Beach Cities.
New power plants were required to feed the resulting demand for more electricity. Wetlands close to the ocean were targeted for the low cost land and proximity to ocean water for economical cooling.
Plans for a regional park were abandoned. The Salt Lake was filled as Southern California Edison began construction of the initial portion of the current AES power plant. The Art Deco/gothic architecture of this older portion of the plant is considered historically significant architecture for the City.
The Case Against High Density Residential at the AES Site 9 Salt Lake location superimposed on power plant. This image shows all units, not just the initial set.
Note the oil tanks that were eventually torn down in 2006. The active wetlands are mostly in the tank locations.
h. 1960’s: Construction of last set of units
As power demand grew and the original plant became outdated, SCE added the last units to the site which were all completed and operational by 1968.
i. 1980’s: Redondo “Fun Park” proposed for AES site
In the 1980’s residents drove for replacement of the power plant with a “Fun Park”. The resident drive was rejected by SCE.
j. 2005: Residents vote for parkland at AES site
The City put the future of the AES site to an advisory vote – giving voters two alternatives for the site:
parkland with no residential development, or Mixed Use development that would allow up to 350 residential units. Despite biased and deceptive ballot language (see Figure 1), the voters favored the park alternative for the site.
k. 2006: Oil tanks torn down
The SCE power plant had been converted to natural gas so the original five oil tanks were no longer required. SCE completed removal of the oil tanks by 2006 but left the containment revetments and much of the related infrastructure was abandoned in place.
The Case Against High Density Residential at the AES Site 10 l. 2010 Residents vote to add Park zoning to AES site The City put “Measure G” to the voters of Redondo. Measure G consisted of new zoning for the harbor area including adding “park” as a permitted use on the AES site. The park zoning component was heavily emphasized in campaign activities for the measure. m. 2015: Coastal Commission finds wetland activity
Around 2010, state water control board set shut down dates for the remaining ocean water cooled power plants due to the drastic environmental impact on larval marine life. Current plant owner, AES submitted plans to construct a new power plant that would be air cooled. As the different state agencies deliberated on AES’s application, the Coastal Commission found that wetlands were active on about 6 acres of the AES site, primarily around the old oil tank sites. The Coastal Commission ordered AES to halt dewatering activities. Audubon Society began regular surveillance of birds at the wetlands, identifying over 130 species using the site. It was noted during this surveillance that AES had restarted dewatering. The Coastal Commission demanded AES stop dewatering activities. The wetland activity continues today.
Canadian Geese landing at AES wetlands. Ruddy ducks are nesting in the wetlands grasses to the left. n. 2018: AES sells property
AES announced the sale of its property to real estate investors. The new buyer committed in writing to offer up to 25 acres of public parkland to the City at a discounted price. o. 2018-2019: City successful in start of park funding for AES site
In 2018, the California Coastal Conservancy awarded the City of Redondo Beach a $500K grant to plan for parkland/wetlands restoration at the AES site. In 2019, California Natural Resources Agency announced the award of $4.8M grant for the planning and acquisition of parkland at the AES site.
The Case Against High Density Residential at the AES Site 11 p. 2020: LA County forms park financing mechanism
LA County formed an Enhanced Infrastructure Financial District to facilitate funding a 25 acres at the AES site. This mechanism would divert a tax increment on County taxes generated around the AES site to fund acquisition and development costs of a public park on the AES site.
This historical track record shows the rich cultural history of the site as well as the repeated commitment of Redondo residents and local and state agencies to parkland uses for this site. Using this site for high density residential development flies in the face of the recreational potential and historic cultural value of this site to the community and region and ignores the repeated commitment of the community and local and state agencies to invest in the site for this unique recreational and cultural value.
8. Environmental Impacts
The environmental impacts of converting the AES site to high density residential have been documented in preceding paragraphs and in numerous EIR’s previously conducted on such uses. To summarize the impacts:
• Cultural impacts in the development over a former Chowinga village, over the state designated historical site of the Salt Lake that was critical to the area, and to the architecture of the original portion of the power plant.
• Environmental impacts to the wetlands and the over 130 species of birds that use the wetlands at the site already.
• Traffic impacts throughout the city
• Coastal access impacts to the harbor for coastal dependent recreational and commercial uses.
9. Summary and Conclusions
The AES site has been important to the residents of Redondo since its earliest days. Time and time again, development interests trumped the repeated desire of the community to honor this site with significant parkland and wetland development. Given the proven commitment of the community to cultural, recreational and environmental uses of the site, it is extremely unlikely the community would vote to support a meaningful amount of residential uses of the site. And even if somehow residents rolled over, you still have the Coastal Act and the Coastal Commission. There are far better and less impactful alternatives for high density residential development in the City. The AES site is about as bad a site as you could possibly choose for high density residential. We should not waste everyone’s time pursuing this dead end. Let’s not add this to the other expensive wastes of time in the harbor area – Heart of the City, Measure B, and the CenterCal Mall. I hope we learn from history rather than repeat it.